No Recruitment Fee Rule: What Manning Agents Can’t Charge

Manning agent fees cannot generally be charged to seafarers under MLC 2006. Standard A1.4 says recruitment, placement and employment-related charges must not be borne directly or indirectly by the seafarer. Limited exceptions include certain personal documents and a national statutory medical certificate. Visa costs must be borne by the shipowner. 

This rule applies to covered private recruitment and placement services operating under a national regulatory system. The aim is simple: a seafarer should not have to pay a recruitment agency to obtain a job at sea.

For Indian manning agencies, the MLC requirement also needs to be read alongside the current RPSL rules on recruitment costs and cost allocation.

What does the MLC say about seafarer recruitment fees?

The MLC 2006 sets a clear principle under Standard A1.4. Where a Member has a system for private seafarer recruitment and placement services, its laws, regulations or other measures must require that fees or other charges for recruitment, placement or providing employment are not borne by the seafarer, directly or indirectly, in whole or in part.

There are limited exceptions.

A seafarer may bear the cost of:

• A national statutory medical certificate
• A national seafarer’s book
• A passport or similar personal travel document

The cost of a visa is excluded from these exceptions and must be borne by the shipowner. 

This creates an important distinction between a personal document cost and a recruitment or placement charge.

For example, a passport is a personal travel document. A “job processing fee” charged by a manning agent to secure employment is a recruitment-related charge.

The label used on an invoice does not change the nature of the cost.

For a broader overview of MLC 2006 compliance and certification requirements, see our MLC 2006 Certification guide.

Why does the MLC prohibit recruitment charges to seafarers?

The rule protects access to employment. Regulation 1.4 says seafarers should have access to an efficient, adequate and accountable recruitment and placement system without charge to the seafarer.

That matters because recruitment costs can become a barrier to finding work. A seafarer who has to pay an agency simply to obtain a job can be exposed to debt, hidden charges or pressure to accept unsuitable employment.

The MLC therefore puts the recruitment cost burden on the recruitment system and, where applicable, the shipowner rather than treating employment as something the seafarer must purchase.

The ILO’s application guidance also confirms that private recruitment and placement services must not charge seafarers for their services.

Which seafarer recruitment fees are prohibited?

The basic rule covers charges connected with:

• Recruiting a seafarer
• Placing a seafarer with a shipowner
• Providing employment to a seafarer
• Processing a recruitment or placement
• Obtaining employment through a recruitment service

The prohibition also covers indirect charges.

That means an agency should be careful about creating a charge that has a different name but serves the same purpose.

Examples of charges that can raise a compliance issue

Charge or payment	MLC treatment
Recruitment fee	Generally cannot be charged to seafarer
Placement fee	Generally cannot be charged to seafarer
Fee for obtaining employment	Generally cannot be charged to seafarer
Job processing fee	Cannot be used to bypass the recruitment fee rule
National statutory medical certificate	May be borne by seafarer
National seafarer’s book	May be borne by seafarer
Passport or similar personal travel document	May be borne by seafarer
Visa	Shipowner bears the cost
Recruitment agency service cost	Cannot be passed to seafarer as a recruitment charge

The exact application of any payment should be checked against the applicable national rules and the relevant employment or collective bargaining arrangements.

Can a manning agent charge a placement fee to a seafarer?

No, not where the MLC’s recruitment and placement fee rule applies. Standard A1.4 specifically covers fees and charges for recruitment, placement and providing employment. Those costs cannot be shifted to the seafarer, either directly or indirectly, except for the limited personal-document and medical-certificate costs specified in the Standard.

So a manning agent should not tell a seafarer:

“You have to pay us because this is a placement fee.”

The MLC rule is designed to prevent exactly this type of recruitment cost from being imposed on the person seeking employment.

What if the agency calls it an administration fee?

The name alone does not solve the problem. If the payment is required because the agency is finding employment or placing the seafarer with a shipowner, it can still fall within the prohibited recruitment or placement charges.

A good compliance test is: Would the seafarer have to make this payment if there were no recruitment or placement service involved?

If the answer is no, the agency should examine the payment carefully before charging it.

Which costs can a seafarer legally pay?

The MLC does allow certain costs to be borne by the seafarer. The key exceptions under Standard A1.4 include:

National statutory medical certificate

The cost of obtaining a national statutory medical certificate can be borne by the seafarer.

This should not be confused with every medical examination connected with joining a particular ship or job. National rules and the applicable employment arrangements can affect the treatment of particular medical expenses.

National seafarer’s book

The seafarer may bear the cost of obtaining the national seafarer’s book.

Passport or similar personal travel document

The seafarer may bear the cost of a passport or similar personal travel document.

The ILO FAQ specifically explains that, in the absence of a relevant provision in the SEA or applicable collective bargaining agreement, the seafarer would generally be expected to cover the passport or similar travel document. 

These exceptions should not be expanded into a general permission to charge recruitment costs.

Who pays the seafarer’s visa under MLC 2006?

The shipowner pays the cost of the necessary visa. Standard A1.4 specifically excludes visa costs from the personal-document exceptions that may be borne by the seafarer.

The ILO FAQ states that, in the absence of a relevant provision in the SEA or applicable collective bargaining agreement, the seafarer would generally cover the passport or similar travel document, while the shipowner would pay the cost of a necessary visa. 

There is an important limitation here. The ILO FAQ says the MLC does not settle every question about travel expenses a seafarer might incur to obtain a visa. For example, it does not establish a universal rule on whether travel to another country to obtain a visa forms part of the shipowner’s visa-cost obligation. 

So agencies should avoid making broad claims such as “every expense related to a visa is always covered by the shipowner.”

Can a manning agency charge for a medical examination?

The answer depends on which medical examination is involved. The MLC allows the cost of obtaining a national statutory medical certificate to be borne by the seafarer. 

But a separate medical examination required for a particular job, shipowner or deployment can involve different cost-allocation rules.

For Indian RPSL companies, the current national framework makes an important distinction between a seafarer’s own general medical certificate and job-specific pre-sign-on or post-sign-off medical examinations.

LegalBabu’s updated RPSL responsibilities guide explains the current Indian cost allocation, including the distinction between personal medical certification and job-specific medical examinations.

This is an area where agencies should keep their invoices and medical instructions clear. A vague “medical processing fee” can create unnecessary disputes.

Can a seafarer be charged for a passport?

Yes, the MLC allows the cost of a passport or similar personal travel document to be borne by the seafarer.

But there is a major difference between:

• Paying for your own passport, and
• Paying a manning agency a fee to obtain employment.

The first falls within an express exception under Standard A1.4. The second is a recruitment or placement charge and generally cannot be imposed on the seafarer.

The ILO FAQ also distinguishes the cost of personal travel documents from the recruitment service itself. 

Can an agency recover recruitment costs from the shipowner instead?

Yes. The MLC’s prohibition is aimed at charges being borne by the seafarer. It does not prevent a recruitment and placement service from being paid by a shipowner.

In fact, the ILO’s supervisory material expressly notes that the MLC allows recruitment and placement services to obtain remuneration from employers while prohibiting charges to seafarers for recruitment or placement.

This creates a practical commercial model:

Shipowner → pays recruitment service

Seafarer → does not pay for recruitment or placement

That structure helps keep the employment relationship separate from the agency’s commercial relationship with its client.

What does the no recruitment fee rule mean for Indian RPSL companies?

For an Indian RPSL company, the MLC rule should be read together with India’s current recruitment and placement requirements.

LegalBabu’s current guidance on the responsibilities of RPSL companies states that recruitment or placement itself cannot be charged to the seafarer. It also sets out current Indian rules on costs such as visas, medical examinations, welfare contributions and personal documents.

The practical lesson for an agency is to create a written cost-allocation matrix.

For every common recruitment expense, identify:

1. What is the expense?
2. Who requires it?
3. Who pays it?
4. Is it a recruitment or placement cost?
5. Is it a personal document cost?
6. Is there a national rule that changes the allocation?
7. Is the payment documented?

This makes it much easier for staff to give consistent answers to seafarers.

What does the current RPSL framework say about recruitment costs?

LegalBabu’s September 2026 guide on the RPSL rules and key responsibilities identifies the following current cost allocation:

Cost	Current RPSL treatment described by LegalBabu
Visa charges	Shipowner
Job-specific pre-sign-on or post-sign-off medical examination	Shipowner
Seafarers’ welfare fees	Shipowner for Indian ships, with the treatment for other ships set out in the applicable rules
Repatriation or replacement costs for specified foreign-flag placements	RPSL company, under the circumstances described in the rules
Personal medical certificate	Seafarer or someone on the seafarer’s behalf
CDC or identity document	Seafarer
Passport or similar personal travel document	Seafarer
Recruitment or placement itself	Cannot be charged to the seafarer

The table above reflects the current LegalBabu guidance on the 2026 Indian framework. Agencies should verify the precise statutory provision applicable to their individual transaction before invoicing a cost.

What happens if a seafarer is asked to pay a recruitment fee?

The seafarer should first ask for a written explanation of the charge.

That creates a record of:

• Who requested the payment
• How much was requested
• What the payment is for
• Whether it is refundable
• Whether it is linked to employment
• Which company or person requested it

A seafarer should be especially cautious when an agency asks for money before confirming a job or describes the payment as a condition for obtaining employment.

Practical questions from job seekers about agency charges are common online. For example, recent discussions by Indian job seekers have specifically questioned whether agencies can ask candidates to pay medical and visa costs as part of an employment offer.

That makes the distinction between recruitment costs, personal documents and job-specific expenses especially useful in practice.

How should a manning agency structure its fee policy?

A clear written policy is one of the easiest ways to reduce disputes.

A good fee policy should state:

1. Recruitment fees

No recruitment or placement fee is charged to the seafarer where the MLC rule applies.

2. Personal documents

Clearly identify which personal documents the seafarer may have to obtain at their own cost.

3. Medical certification

Separate the national statutory medical certificate from job-specific medical examinations.

4. Visa

State who bears the visa cost.

5. Other expenses

List any other expenses and explain their legal or contractual basis.

6. Receipts

Give a receipt for every permitted payment made by a seafarer.

7. Complaints

Tell the seafarer where to raise a concern if they believe a prohibited charge has been imposed.

The goal is to make the payment rules understandable before the seafarer reaches the joining stage.

How can an RPSL company avoid accidental recruitment fee violations?

Start by reviewing every payment the agency receives from seafarers.

Internal fee audit checklist

• List every payment collected from seafarers.
• Identify the purpose of each payment.
• Remove any recruitment or placement charge.
• Separate personal-document costs from recruitment costs.
• Check who is responsible for visa costs.
• Review medical examination charges.
• Check whether staff use terms such as “processing fee” or “placement fee.”
• Review receipts issued to seafarers.
• Check website and advertisement wording.
• Train recruitment staff on permitted and prohibited charges.
• Keep evidence for every permitted expense.

This matters because a policy can be compliant on paper while staff still collect the wrong fee in practice.

Can a manning agent deduct recruitment costs from a seafarer’s salary?

A recruitment charge does not become acceptable simply because the agency deducts it from wages instead of collecting it upfront.

Standard A1.4 prohibits recruitment and placement charges from being borne directly or indirectly, in whole or in part, by the seafarer.

So an agency should not attempt to avoid the rule through:

• Salary deductions
• Joining advances
• Reimbursement arrangements
• Mandatory agency memberships
• Placement deposits
• “Refundable” recruitment charges

The substance of the payment matters.

Can a manning agent charge a refundable security deposit?

A refundable label does not automatically make a recruitment charge acceptable.

If the deposit is required as a condition for recruitment or placement, the agency should examine it carefully against Standard A1.4 and the applicable national rules.

The MLC prohibits fees or other charges for recruitment, placement or providing employment from being borne by the seafarer, subject to the specified exceptions. 

An agency should therefore obtain regulatory advice before introducing any deposit connected with recruitment.

What if the seafarer voluntarily agrees to pay the agency?

Voluntary consent does not automatically create an exception to the MLC rule. The Standard says the charges cannot be borne directly or indirectly by the seafarer.

So an agency should not rely on a statement such as:

“The seafarer agreed to pay.”

The correct question is whether the payment is one that the applicable rules permit the seafarer to bear.

What evidence should a manning agency keep about recruitment fees?

A good audit trail should allow the agency to show exactly how costs were handled.

Useful records include:

• Fee and cost policy
• Seafarer invoices
• Receipts
• Bank payment records
• Medical invoices
• Visa-related documents
• Passport-related documents
• Recruitment agreements
• Shipowner agreements
• Employment agreements
• Internal approval records
• Complaints relating to payments
• Refund records, where applicable

The MLC also requires applicable private recruitment and placement services to maintain an up-to-date register of seafarers recruited or placed through them, available for inspection by the competent authority.

Guideline B1.4.1 also recommends verifiable operational practices and complete records covering matters such as qualifications, employment records, personal data relevant to employment and relevant medical data.

How should shipowners check recruitment fees charged by their agencies?

Shipowners should include recruitment charges in their agency due diligence.

A practical review can ask:

Question	What to check
Does the agency charge seafarers?	Review its fee policy and sample receipts
Are recruitment charges prohibited?	Confirm the agency’s process
Who pays visa costs?	Check the agreement and actual invoices
Who pays job-specific medical costs?	Check the applicable national rules and contract
Are personal documents separated?	Review receipts
Are complaints recorded?	Check the complaint register
Are costs transparent?	Compare the agency policy with actual transactions

This is particularly important when the shipowner uses an agency in a country where the MLC does not apply. Regulation 1.4 places a due diligence responsibility on the shipowner in that situation. 

For broader agency checks, LegalBabu’s RPSL annual compliance service covers ongoing compliance, records, audits and recruitment-related controls.

What should a seafarer do before paying a manning agency?

Before making any payment, ask these questions:

1. What exactly am I paying for?
2. Is the payment connected to recruitment or placement?
3. Who legally bears this cost?
4. Is the charge required by national law?
5. Will I receive a written receipt?
6. Is the payment refundable?
7. Is the payment mentioned in my employment documents?
8. Can the agency explain the legal basis for the charge?

If the answer is unclear, do not assume that the payment is permitted simply because an agency requests it. A recruitment agency should be able to explain its cost structure clearly.

What is the difference between recruitment fees and personal document costs?

This distinction is central to the MLC rule.

Type of cost	General MLC treatment
Recruitment fee	Seafarer should not bear it
Placement fee	Seafarer should not bear it
Employment procurement charge	Seafarer should not bear it
Passport	May be borne by seafarer
National seafarer’s book	May be borne by seafarer
National statutory medical certificate	May be borne by seafarer
Visa	Shipowner bears the cost
Other travel costs connected with obtaining a visa	MLC does not fully define the treatment

The last row needs care. The ILO FAQ specifically says the MLC does not address whether travel costs incurred to obtain a visa are included in the shipowner’s obligation to cover visa costs. 

That is why agencies should not present every travel-related expense as automatically covered or automatically payable by the seafarer.

What does fair recruitment mean for seafarers?

Fair recruitment under the MLC goes beyond simply removing a placement fee.

Standard A1.4 also requires measures that prevent recruitment and placement services from using means, mechanisms or lists intended to prevent qualified seafarers from obtaining employment.

The broader recruitment process should therefore protect seafarers from:

• Improper recruitment charges
• Unfair barriers to employment
• Misleading employment information
• Improper restrictions on access to jobs
• Poor recordkeeping
• Lack of information about employment rights

For agencies, fair recruitment works best when the rules are built into everyday procedures rather than handled only when a complaint appears.

What are the most common mistakes with manning agent fees?

Charging a “registration fee”

If the fee is really required to obtain employment, renaming it does not solve the compliance issue.

Charging a “placement fee”

This directly falls within the type of charge Standard A1.4 addresses.

Making the seafarer pay the visa

The MLC specifically assigns visa costs to the shipowner. 

Mixing personal medical costs with job-specific medical costs

These can have different cost treatment. The agency should identify exactly what medical service is being provided.

Deducting the charge from salary

Indirect charges remain a concern because the Standard covers costs borne directly or indirectly by the seafarer.

Taking a refundable deposit

Refundability alone does not make a recruitment-related charge permissible.

Giving verbal explanations only

Written cost policies and receipts are much easier to audit and much safer for both the agency and seafarer.

FAQs